Comments

(Late Submission)Please see the attached letter from Robert Vrij, President
Alcatel-Lucent, in response to a letter dated April 2, 2009 by Zhone's
CEO, Mory Ejabat, regarding the American Recovery and Reinvestment Act's
"Buy American" provision.

Sincerely,

Michael Thomas McMenamin

Sr. Counsel - Managing Director

Americas Region

Alcatel-Lucent

1100 New York Avenue, NW

Suite 640 West Tower

Washington, DC 20005

Direct Number: 202.312.5916

Mobile: 703.307.4920

mcmenamin@alcatel-lucent.com

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(Late Submission)The Rural Internet and Broadband Policy Group respectfully submits the attached document as our comments to the National Telecommunications and Information Administration and the Rural Utilities Service.

(Late Submission)Please find attached comments for the National Telecommunication and Information Administration (NTIA) and Rural Utilities Service (RUS) Broadband Provisions of the American Recover and Reinvestment Act of 2009. These comments are submitted in accordance with the instructions found in the Federal Register posting of March 12, 2009. These comments are submitted on behalf of the State of Florida. Thank you.

(Late Submission)As an attendee of the Las Vegas public meeting, I noticed a lot of dialog and confusion around the definition of "broadband" -- specifically, how broadband should be defined for purposes of the recovery program.

As a 2006 appointee to the California Broadband Task Force (see http://www.calink.ca.gov/taskforcereport/) and Chair of the group's Emerging Technologies and New Applications working group, we struggled with the exact same issue and conflicts, namely, not wanting to draw a firm line at a certain bandwidth which may arbitrarily exclude a specific technology, or make our findings obsolete a short while after our report was published.

To solve this issue, we recognized that "broadband" was a spectrum of bandwidths that enabled an end-user to perform online applications at a reasonable performance to that user. We also included certain "must-have" features for broadband (always-on, maximum ratio of downstream-to-upstream speeds). The definition, taken from page 12 of the report referenced above, is included as an attachment to this comment.

As you will see in the attachment, we recognized that broadband speeds are likely to improve by orders of magnitude in a very short period of time (as demonstrated by speed improvements to date), and included a catalog of applications and uses that are available at each of the bandwidth milestones. I believe that by viewing the broadband bandwidth spectrum using a scale that increases by factors of 10 (1Mbit, 10Mbit, 100Mbit, 1000Mbits, etc.) is a much more useful approach to defining broadband than just trying to define a narrow set of bandwidth speeds. Much like the Richter scale, which measures seismic activity in magnitudes 10 times larger than the previous level, I believe you will find such a view and definition of "broadband" to better serve everyone, and not threaten the future relevance of your findings.

If I can provide further information, please do not hesitate to contact me.

(Late Submission)Maximum impact can be achieved through funding that goes through a knowledgeable state-wide intermediary that can underwrite, fund/finance a variety of regional and community based broadband projects, thus achieving greater reach and impact. See attached concept paper for how this could work in New Hampshire. The model is appropriate for other states as well.

BTOP focus should be on educating the public about the true benefits of ubiquitous broadband infrastructures with major emphasis on the formation of local Public/Private Partnerships (P3's) playing an integral role in establishing Community, Municipal, City or County wide broadband infrastructures, communications, internet access and services.

These ground level P3Ã¢â‚¬â„¢s will invite carefully designed and GSA specific criteria that will lead to streamlining grant/loan application processes, network implementation and deployment, monitoring and transparency for BTOP initiatives in Urban, Suburban AND Rural markets.

Attached is IEEE-USA's comments on the new Broadband Technology
Opportunities Program (BTOP)
being established by the National Telecommunications and Information
Administration (NTIA) as contained
with Section 6001 of the American Recovery and Reinvestment Act of 2009
(Recovery Act).

Should you have any questions or need more information, please contact
Deborah Rudolph at (202) 530-8332, or at d.rudolph@ieee.org.

The members of the Independent Telephone and Telecommunications Alliance (ITTA) are mid-size telecommunications providers that serve nearly 30 million customers in 44 states. Our members serve some of the most rural parts of the country, where technological and geographical limitations, combined with market economics, create formidable challenges to high-speed Internet deployment.
Consistent with the points we made throughout the drafting of the American Recovery and Reinvestment Act of 2009 (ARRA), ITTA members strongly believe that the $7.2 billion in broadband stimulus money should be focused on unserved parts of our country. Building out broadband to the unserved will do more to create jobs and open up new economic opportunity than diverting money to other purposes. Making broadband available everywhere will also facilitate other ARRA objectives, such as intelligent transportation systems, electronic medical health records and smart-grid technology. Unless ARRAÃ¢â‚¬â„¢s limited funds are focused on bridging the gap between the broadband haves and have nots, ARRA could actually widen todayÃ¢â‚¬â„¢s digital divide. ARRA is an excellent start to close existing broadband gaps, but it is vitally important to ensure that funding is utilized as efficiently as possible to extend broadbandÃ¢â‚¬â„¢s reach as far as possible. Thus, connecting the unserved should be the agencyÃ¢â‚¬â„¢s foremost priority.
The full potential of broadband remains beyond the grasp of many Americans living in rural and other high-cost and hard-to-serve parts of the country. A recent study by the U.S. Department of Agriculture highlighted that, due to higher costs and low adoption rates, at least 9.3% of rural households do not have access to any type of broadband services. In spite of the challenges of serving Rural America, ITTA members have invested hundreds of millions of dollars to bring the opportunity-building tool of broadband to 85-90% of their customers, which is in line with the availability in the more urban parts of our country.

Given current cost and demand conditions, however, we are unable to make a reasonable business case for building out broadband to the most rural areas that remain. This is why it is vitally important that the broadband stimulus funding be targeted as grants to areas that are currently unserved.
The broadband stimulus funding brings the opportunity to connect all Americans to broadband one step closer, and we must not let this opportunity pass us by. The stimulus funding is an important Ã¢â‚¬Å“down paymentÃ¢â‚¬Â on AmericaÃ¢â‚¬â„¢s broadband future, but the enormity of the task requires focus and discipline in this first step.
Sincerely,

During the two weeks of BTOP public meetings there were several comments and questions regarding the use of the 2.5GHz Educational Broadband Service (EBS) to facilitate implementation of BTOP initiatives.

This 2.5GHz band has been under a lot of scrutiny because of the way it was acquired by Sprint (Nextel) and Clearwire.

This 2.5GHz spectrum could be considered a VERY valuable Community asset and be used to greatly enhance the BTOP in all Urban, Suburban AND Rural markets within the United States.

This petition contains an introduction explaining the FCC rule and policy changes in the 2.5GHz band that allowed Sprint (Nextel) and Clearwire to negotiate long term leases with our local Community Colleges, Universities, School Boards, Churches and other local non-profits from which this spectrum was "acquired".

Due to the FCC policy and rule changes Sprint (Nextel) and Clearwire have acquired long term lease rights to our 2.5GHz band in over eighty-five percent of major metropolitan service areas (MSA)within the United States.

There are many questions and concerns surrounding these dealings. The public BTOP meetings helped to bring these concerns to light.

This is an extremely important issue and as 4G or WiMAX teeters on the fence of becoming a viable solution for BTOP initiatives it is important to examine and identify all assets available to bring the BTOP initiatives to frution and to develop a practical and sustainable nationwide broadband plan.

(Late Submission)I am pleased to submit this white paper, formally endorsed by organizations that represent all 50 states, over 2200 colleges and universities, 30 state and regional networks, 44 corporations, and international reach to networks in 90 countries. America's state and regional network reach over 55,000 institutions including K-12 schools, community colleges, colleges and universities, libraries, hospitals, clinics, medical research centers, agricultural extension sites, museums, and community and performing arts centers.

My name is Greg Johnson, and I am the CTO for the Virginia
Commonwealth
University Health System (VCUHS), a major inner-city Academic Medical
Center, located in downtown Richmond Virginia. I am writing you to
discuss
the possibility of developing a grant proposal and submittal in support
of
our Electronic Medical Record system as well as other clinical and
non-clinical systems utilizing wireless technology.

Several months ago we opened up our new Critical Care Hospital (CCH) -
a
state-of-the-art facility designed to maximize the integrated usage of
a
wide variety of disparate wireless systems, ranging from 802.11
wireless
Networks, to Telemetry Systems, to ASCOM & Vocera VoIP communications
systems, paging systems, cell phones, sophisticated NICU monitoring
equipment, etc. The CCH has been extremely successful in its
implementation
of this wireless technology, resulting in improved patient outcomes,
greater patient care and patient safety. The backbone for this
complex,
cutting-edge technology is a system called The InnerWireless Horizon
System, which is essentially a passive Distributed Antennae System
(DAS)
which was installed during the physical construction of the CCH. This
system facilitates the usage of a wide array of wireless technologies
between the frequency range of 400 MHz to 6000 MHz , enabling and
providing
ubiquitous, stable, and reliable coverage throughout this large (15
story,
376,000 sq. ft.) facility. The success and adoption of the technology
has
been extremely well received by clinicians and patients alike. In terms
of
the complexity of the environment we have created, it is one of the
only
Institutions in the world that has achieved this level of integration
and
success.

That's the good news. Now to the reason for my email. In the realm of
unintended consequences, we have created a situation wherein the rest
of
our Medical Center, which does not enjoy an InnerWireless backbone,
has
quickly become a "sore point" amongst our clinicians as they have
readily
seen that they are not able to provide the same level of service, use
the
same level of integrated technology, or have the same level of
wireless
technology reliability as in the CCH. This is viewed as an
unacceptable
situation. However, in order for us to retrofit our pre-existing
physical
structures (specifically our Main and North Hospitals both of which are
on
our Urban campus, as is the CCH), we would need to spend somewhere in
the
neighborhood of $3-$3.5M to bring the InnerWireless system into the
existing facilities.

It is our belief that by doing so, not only would the rest of the
Medical
Center enjoy the same high level of patient services as the new CCH
does,
but it will raise the level of care in the Central Virginia area
significantly, as well as serve as a model for other Health Systems
throughout the country. Working in partnership with our vendor,
InnerWireless, we would like to work with you to help us in crafting a
proposal that would meet your grant submission criteria so that we
could
apply for a grant enabling us to achieve this retrofit and realize all
of
the benefits noted above.

I would very much appreciate setting up a time to either talk with you,
or
perhaps even meet with you in person, to discuss our proposal, and how
we
can go about developing this proposal. I should note that neither
myself
nor my team, nor our partners at InnerWireless have any grant writing
experience, and would therefore need your assistance in developing a
viable
proposal.

Please feel free to contact me and/or Mr. Frank Lasky of InnerWireless
at
the numbers listed below, or via email. I look forward to speaking with
you
in the very near future.

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VCU Health System
http://www.vcuhealth.org

Please accept the attached comments of Cinergy MetroNet, Inc. I tried
to upload it online but your website seems to not be accepting any
additional filings. Please contact me if you have any questions.
Thanks for your attention to this matter.

John Chuang
Corporate Counsel
(913) 754-3339

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The American Recovery and Reinvestment Act of 2009 (ARRA)charges the National Telecommunications Information Administration (NTIA) and the Rural Utilities Service (RUS) with the task of disbursing $6.85 billion dollars via grants for broadband infrastructure and adoption programs. The FCC has also recently announced its intent to develop a national broadÃ‚Â­band plan.

The mission of Homework Central, Inc. is to improve children's academic achievement by providing a literacy-rich, safe and nurturing environment through one-on-one mentoring relationships with caring teenagers and adults. We are providing homework assistance to children who are academically at-risk and do not have stable academic assistance at home. During the school year 2008-2009, we have served 45 children of which 71 percent of their families are at or below poverty level and 33 percent are in an Individual Education Program at school.

A recent donation of three new computers through Connect Ohio enabled our program to help these at-risk children to reach their full potential. The No Child Left Offline program, which is made possible by the public-private partnership of Connect Ohio, is helping us to add a computer lab to our reading room and life skills activities area.

Next year's goal is to be able to serve up to 60 children in our program. Our ultimate goal is that additional community organizations will provide similar programs in their neighborhoods. We are dedicated to offering our assistance to these programs. To date, two other community organizations have patterned their programs after Homework Central, Inc.

As you implement the Broadband Data Improvement Act and the American Recovery and Reinvestment Act, and as you develop a national broadband plan for America, I urge you to support and fund programs such as Connect Ohio. The Connect Ohio program works across the state to stimulate demand for broadband and computer use through local technology planning, broadband mapping, local research, and digital literacy projects such as No Child Left Offline.

(Late Submission)I've attached [1] NARUC's letter signed by 90 commissioners representing 39 states [2] a handout hand-delivered to several NTIA/RUS staff with specific comments from several states [3] two related letters filed in this proceeding by two additional commissions endorsing key aspects of the NARUC filings.

(Late Submission)Please find attached Filling Comments on Section 6001 of the American Recovery and Reinvestment Act of 2009. These comments are being filed on behalf of Association of Public-Safety Communications Officials (APCO) International.

World Cable is pleased to have this opportunity to comment on the
Joint Request
for Information (the Ã¢â‚¬Å“ROIÃ¢â‚¬Â) published by the National
Telecommunications and
Information Administration (Ã¢â‚¬Å“NTIAÃ¢â‚¬Â) and the Rural Utilities Services
(Ã¢â‚¬Å“RUSÃ¢â‚¬Â) on March
12, 2009. As discussed below, World Cable is seeks to assure that the
communities it
serves qualify for grants pursuant to the statutory goal of
Ã¢â‚¬Å“provid[ing] improved access to
broadband services to consumers residing in underserved areas of the
United StatesÃ¢â‚¬Â.
World Cable urges NTIA to construe the term Ã¢â‚¬Å“underservedÃ¢â‚¬Â to recognize
the needs of
ethnically diverse populations residing in urban areas, who are
frequently low-income
and financially disadvantaged and who are currently not receiving
affordable, sustainable
services. World Cable further urges NTIA and RUS to recognize that
not all
Ã¢â‚¬Å“underservedÃ¢â‚¬Â populations live in rural or remote areas, but can also
live in quite urban
settings, literally around the corner from Ã¢â‚¬Å“well-servedÃ¢â‚¬Â populations.

World Cable provides very cost effective, creative triple-play
solutions to certain
residential buildings in New York City. The triple-play solution
provides a voice, video
and data services at cost effective rates in buildings in New York
City. World Cable
upgrades the infrastructure in buildings throughout New York where the
incumbent local
exchange carrier (ILEC) has no current upgrade plans and provides new
services to the
residents, mostly immigrants, at affordable prices that include
content from their nations
of origin. World Cable provides a very secure, cost effective Internet
access service
operating at up to 150 times the speed of dial up Internet access and
up to two times as
fast as dsl. Residential and small business customers are capable of
securely using World
CableÃ¢â‚¬â„¢s services anywhere in their homes and common areas. For the
past 5 years,
World Cable has contracted with residential property developers in New
York City to
provide a triple play of services in residential multi-family dwelling
complexes
Broadband Technology Opportunities Program
U.S. Department of Commerce
April 13, 2009
Page 2

encompassing nearly 30,000 residential units. Although World Cable
currently has
networks deployed only in properties in New York City, it is looking
to expand its
services to other major urban areas.

The American Recovery and Reinvestment Act of 2009 (the Ã¢â‚¬Å“ActÃ¢â‚¬Â)
allocated a
total of $4.7 billion to NTIA for a new Broadband Technology
Opportunities Program
(Ã¢â‚¬Å“BTOPÃ¢â‚¬Â). The Act sets forth that the BTOP is intended to provide
improved broadband
access in Ã¢â‚¬Å“underserved areas.Ã¢â‚¬Â In support of the effort to provide
broadband service to
Ã¢â‚¬Å“underserved areasÃ¢â‚¬Â the BTOP funds may be utilized to provide
broadband education,
training, access, equipment, and support to organizations that provide
outreach, access,
equipment, and support services to facilitate greater use of broadband
service by low-
income, unemployed, aged, and otherwise vulnerable populations and
stimulate the
demand for broadband, economic growth, and job creation. Consistent
with these
objectives, BTOP competitive grants are available, among other things,
for acquisition of
broadband equipment, instrumentation, networking capability, hardware
and software,
digital network technology, and infrastructure; deployment of
broadband services and
related infrastructure; facilitating access to broadband by
low-income, unemployed, aged,
and Ã¢â‚¬Å“otherwise vulnerableÃ¢â‚¬Â populations in order to provide educational
and employment
opportunities; and other matters consistent with the purposes behind
BTOP.

As Free Press noted in a report published as recently as April 7,
20091,

Ã¢â‚¬Å“[f]or many urban residents, high-speed Internet services,
which typically cost $40 to $60 per month, are simply too
pricey. Compounding the Internet access problem, many
people are unable to afford a computer or lack the skills to
navigate the Web. And just like their rural counterparts,
some urban areas have been redlined by Internet service
providers that refuse to offer service to communities that
may not provide as large a financial return. Many urban
residents are locked out, unable to participate fully in the
digital era. TheyÃ¢â‚¬â„¢re prevented from applying for jobs,
telecommuting, taking online classes or even finishing their
homework. ItÃ¢â‚¬â„¢s becoming increasingly clear that Internet
connectivity is key to a sound economy and could assist
those hit hardest by the economic downturn.Ã¢â‚¬Â

It is therefore critical that the NTIA and RUS consider the
economically
disadvantaged living in large, urban centers when establishing a
definition of what is
Ã¢â‚¬Å“underserved.Ã¢â‚¬Â The Joint Explanatory Statement released by the
Congressional conferees
confirms than, in evaluating each application, NTIA must consider
whether an

1
Ã¢â‚¬Å“Wired Less: Disconnected in Urban America,Ã¢â‚¬Â released April 7, 2009,
available at www.freepress.net.

Broadband Technology Opportunities Program
U.S. Department of Commerce
April 13, 2009
Page 3

Updating broadband access in the multiple dwelling unit complexes
(MDUs) in
which these vulnerable residents live is a highly efficient way to
implement the goals and
policies of the Act. Grant funds would be used for acquisition of
broadband equipment,
instrumentation, networking capability, hardware and software, digital
network
technology, and infrastructure and to deploy broadband services and
related
infrastructure. Indeed, but for the availability of BTOP funding, it
can be virtually
impossible to sustain a business case that allows for the lower
pricing that Free Press
notes will be an essential element of closing the Ã¢â‚¬Å“broadbandÃ¢â‚¬Â gap that
now exists
between the advantaged and disadvantaged elements of society.

Broadband access will provide increased opportunities for residents
served by
World Cable to seek employment, work from home, and study and learn
from home
through access to on-line educational opportunities for adults and
school-aged children
alike, and even facilitate over time the provision of telemedicine and
other health care
benefits within these vulnerable communities.

World Cable encourages NTIA to recognize such proposals as eligible
for BTOP
funding in an Ã¢â‚¬Å“underservedÃ¢â‚¬Â area. World Cable also hopes to obtain
funding that will
allow these vulnerable populations to obtain the customer premises
equipment that are
also key to their ability to fully utilize the enormous advantages
that broadband provides.
Indeed, by providing these populations access to the number of
applications available to
other segments of the populace, and by providing content in their own
language, these

Broadband Technology Opportunities Program
U.S. Department of Commerce
April 13, 2009
Page 4

residents are able to reduce their overall monthly communication
costs, while also
accessing the crucial broadband services required in todayÃ¢â‚¬â„¢s economic
world.

In conclusion, the term Ã¢â‚¬Å“underservedÃ¢â‚¬Â must include those populations
in urban
centers who do not have access to affordable broadband facilities in
their residence. The
inclusion of these services will allow NTIA to achieve the objectives
of the BTOP:
increasing employment, introducing access to vulnerable, underserved
urban populations,
and providing service to those who would not be served during the time
frame
contemplated by the Act as quickly or as affordably at sustainable
rates. We urge NTIA
and RUS to include these elements as part of its broad definition of
Ã¢â‚¬Å“underserved.Ã¢â‚¬Â

(Late Submission)I was able to get streaming text, but video and sound was unavailable. My flash Player and uStream.tv were working just fine on my computer. Perhaps, there were just limited connections available. My question is whether the panel will consider the municipal special purpose local Goverment Entity ("LGE") as a preferred model for grant oversight? Letting a community know that they "own" the network will help increase success.

As long as communities follow their own state law, where applicable (on providing cable tv or telecommunications, or refrain from anti competitive franchising where there is no state law on point) then the communities can become providers of telecommunications with public forum oversight of all the activities. But more importantly this provides a means to leverage momentum in both financing and penetration into rural areas.

This transmission in its entirety are private and confidential. Any
reproduction of the information contained is prohibited. Any person
receiving this transmission by unauthorized parties or error, should
immediately destroy or delete this transmission. This communication is not
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direct consent of the author, of this transmission is prohibited by law.

(Late Submission)Attached is the response of the Rural Independent Competitive Alliance
("RICA") to the March 9, 2009 Joint Request for Information of NTIA and
RUS. RICA's member rural competitive local exchange carriers appreciate
the opportunity to comment on this vital matter.

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(Late Submission)1 - Beehive Telephone was to attend the broadband summit in flagstaff today but oil leak in our plane caused us to ground it (the other one is in St.Lewis) so we won't make it,

2 - we are the largest rural wireless provider in Utah with a one gig back bone from Salt Lake City west to Elko, Nevada and from Idaho south to U.S.6 on the west site, and across Utah's highest mountains to the Lake Powell area and with signals over the Navajo Mt. Chapter of the Navajo Tribe.

3 - we are unable to bring these wireless signals into the Navajo's for reasons: 1) The BLM has not granted us rights of way on Nokai Done where exists an emergency landing strip we maintain and 2) the Navajo Tribe has not granted us a tiny parcel a mile from the Chapter House which would enable a solar power access point that would enable broadband to all of Rainbow City and the Chapter house with ten Gigabyte being available if desired. and 3) recognition we are a utility with all meaning thereto between the Tribe's treaty protection of utility property thereto. We have broadband throughout all of southern Utah from Colorado to Nevada. We are a member of the WISPA national wireless internet association. For more information see wirelessbeehive.com or beehive.net.
Art Brothers, CEO art@beehive.net

(Late Submission)>
comments on RFI_v1.DOC>>
Please find enclosed for filing the Comments of Iowa Health Care, Inc.
in response to the Joint Request for Information of the Departments of
Commerce and Agriculture in the above-reference proceeding. One copy of
the Comments is signed in Adobe pdf format, and the other copy of the
comments (the substance of which is identical) is being filed in MS Word
format (as requested in the Public Notice) and is unsigned.

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Broadband should be simply defined as the network capacity to deliver to all consumers that subscribe to a network, symmetrical Internet access speeds of a minimum of 10 mbps download and 10 mbps upload.

This will allow real-time bi-directional transmission of simultaneous voice, video and data services.

This will enable telemedicine which will reduce health care costs, increase healthcare access and thus improve the quality of the healthcare system as a whole.

This will enable distance learning which will improve the quality of education, increase access to quality education while simultaneously reducing the cost of education.

This will enable access to information services and emergency services thus increasing response times and preparedness for national disaters and emergencies for both the United States citizens and also the first responders.

I could go on but instead I will divest and attach an article that was written in 2001 that shows how broadband could grow the United States economy by 500 billion dollars, if national adoption of a minimum 10 mbps upstream and 10 mbps downstream policy were adopted by the Untied States.

Unfortunately, 9 years have passed, minimal gains have been made towards achieving these speeds and no legislation or policy has enacted to force the incumbent and profitablity providers of this access to increase speeds and as such serve a common good by imporiving the economy.

I am afraid to say that what we are seeing and having to address in the automobile industry with our Big Three automakers has manifested itself in the telecommunications arena.
Hopefully, history will not repeat itself and we will allow a open playing field with the end goal being to get a broadband service to all of our citizens that is swiftly deployed, affordable by all and not aimed at protecting the incumbents who choose to stifle competition through policy as opposed to focusing on strengthening our nations's economy and global ranking for the deployment of true broadband services.

(Late Submission)The State of Alabama submits the attached comments pursuant to the American Recovery and Reinvestment Act of 2009 broadband grant and loan programs, Docket No. 090309298-9229-01.

The ConnectingALABAMA team believes the advancement of (a) broadband deployment on the supply-side and (b) broadband-based applications on the demand-side are vital enablers to the economic opportunity and quality of life for all Americans. As such, we stand in strong support of the Broadband Technology Opportunity Program (BTOP) advanced by the American Recovery and Reinvestment Act (ARRA).